Adaptive US GDPR and Privacy Policy

Adaptive US Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Federal Trade Commission regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

Adaptive US Inc. has certified to the Federal Trade Commission that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Key commitments from Adaptive US

1. Types of personal data collected: Name, Email Address and Postal Address
2. Entities or subsidiaries of the organization also adhering to the Principles: None

• Adaptive US is committed to the Principles all personal data received from the EU and/or Switzerland in reliance on the Privacy Shield

1. Adaptive US collects the name, email address and address to communicate with the customers and partners
2. Please write to Info@AdaptiveUS.com with any inquiries or complaints, including any relevant establishment in the EU and/or Switzerland that can respond to such inquiries or complaints,
3. Adaptive US share name and email id with the LMS provider and marketing partner for providing resources and share information updates

• You reserve the full right to access your personal data,
• You can request us to remove your email id from our systems

1. The EU-U.S. Privacy Shield the independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge to the individual, and whether it is: (1) the panel established by DPAs, (2) an alternative dispute resolution provider based in the EU, or (3) an alternative dispute resolution provider based in the United States,
2. The Swiss-U.S. Privacy Shield the independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge to the individual, and whether it is: (1) the Commissioner, (2) an alternative dispute resolution provider based in Switzerland, or (3) an alternative dispute resolution provider based in the United States,
3. Adaptive US is being subject to the investigatory and enforcement powers of the FTC, the Department of Transportation or any other U.S. authorized statutory body

• Under certain conditions you can invoke binding arbitration,
• Adaptive US may disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and
• Adaptive US expects its partner to comply with internationally acceptable norms with respect to user data privacy

1. Adaptive US shall notify in clear and conspicuous language when individuals are first asked to provide personal information to the organization or as soon thereafter as is practicable, but in any event before the organization uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party.

• In compliance with the Privacy Shield Principles, Adaptive US Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Adaptive US Inc. at: Info@AdaptiveUS.com
• Adaptive US Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment/non-employment relationship.
• Type or identity of third parties to which your organization discloses personal information, and the purposes for which it does so: Adaptive US discloses your name, Email ID and address to the LMS and Lead Nurturing systems providers.
• Choices and means your organization offers individuals for limiting the use and disclosure of their personal data: Adaptive US uses your data to serve your training needs and provide information on new products and services

1. Adaptive US maintains liability of not sharing any personally identifiable information except name and email address which are essential to rendering the services while it transfers customer information onward transfers to third parties.

• In the context of an onward transfer, Adaptive US has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  Adaptive US shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

Introduction

Adaptive US Inc. needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Adaptive US Inc.:

• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organizations — including Adaptive US Inc.— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

• The head office of Adaptive US Inc.
• All branches of Adaptive US Inc.
• All staff and volunteers of Adaptive US Inc.
• All contractors, suppliers and other people working on behalf of Adaptive US Inc.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.

This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• LinkedIn ID
• Any other information relating to individuals

Data protection risks

This policy helps to protect Adaptive US Inc. from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Adaptive US Inc. has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Adaptive US Inc. meets its legal obligations.

LN Mishra 

is responsible for:

• Keeping the board updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• Arranging data protection training and advice for the people covered by this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data Adaptive US Inc. holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

LN Mishra 

is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

Ananya Pani 

is responsible for:

• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Adaptive US Inc. will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorized people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorized people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.
• When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Adaptive US Inc. unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Adaptive US Inc. to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Adaptive US Inc. should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Adaptive US Inc. will make it easy for data subjects to update the information Adaptive US Inc. holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by Adaptive US Inc. are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at [email address]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

 The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. 

Under these circumstances, Adaptive US Inc. will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Adaptive US Inc. aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

[This is available on request. A version of this statement is also available on the company’s website.]

What is this Privacy Policy for?

This privacy policy is for this website www.AdaptiveUS.com and served by Adaptive US Inc. and governs the privacy of its users who choose to use it.

The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.

The Website

This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all US national laws and requirements for user privacy.

Use of Cookies

This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html .

Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.